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ARTICLE · 15 APRIL 2026

It’s April, Do You Know Where Your California Digital Assets License Is?

Jenner & Block LLP
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California's new licensing regime for digital financial asset businesses is no longer on the horizon, it is here. The California Department of Financial Protection and Innovation (DFPI) opened its application portal last month, and the July 1, 2026 compliance deadline is now less than three months away. For companies that anticipate serving California residents with covered digital financial assets services, there is a significant advantage to having a license application in by July 1.

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California's new licensing regime for digital financial asset businesses is no longer on the horizon, it is here. The California Department of Financial Protection and Innovation (DFPI) opened its application portal last month, and the July 1, 2026 compliance deadline is now less than three months away. For companies that anticipate serving California residents with covered digital financial assets services, there is a significant advantage to having a license application in by July 1.

Who Needs a License?

The Digital Financial Assets Law (DFAL), Cal. Fin. Code §§ 3200–3272, requires a license to engage in digital financial asset business activity on behalf of a California resident, whether your company is located in California or not. Covered activity is broadly defined to include exchanging, transferring, or storing a digital financial asset, engaging in digital financial asset administration, holding electronic precious metals on behalf of another person, and certain

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